A Grant Thornton report that assists you with understanding today’s compliance benchmark, the goals for tomorrow and in the ongoing fight against money laundering and terrorist financing.

1. Fall 2012 benchmarking report
Anti-money laundering compliance in
the money services business industry

2. From the practice leader
We believe the experience and I am pleased to present our Anti-
knowledge we’ve gained over the past money laundering compliance in the
few years has placed us in a unique money services business industry: 2012
position to offer insight into the status benchmarking report. We hope that it will
of the industry’s anti-money laundering be used to benefit organizations across the
compliance. This benchmarking report money services and financial institutions
reflects the culmination of public industry, as we believe it brings forward
research, as well as the knowledge information that was not easily accessible.
we’ve gained by completing over 150 We hope this report assists you with
anti-money laundering compliance understanding today’s compliance
program-related engagements. These benchmark, the goals for tomorrow
were focused particularly on the money and in the ongoing fight against money
services business (MSB) industry as laundering and terrorist financing.
well as others including securities
dealers, financial institutions, online
The anti-money laundering team at Grant transaction processing organizations,
Thornton LLP has had the opportunity to trust companies, and government
work with money services businesses— organizations. What’s apparent from
large, small and everything in between— our research and experience is that the
from all across Canada over the past few anti-money laundering compliance
years. It has given us great opportunity to programs of money services businesses
meet those who are connected with are now starting to deliver the desired Jennifer Fiddian-Green
people, cultures and communities from all results. However, it is also apparent that CA.IFA, CFI, CAMS, CMA, CFE
over the world. In our experience the many MSBs need to start focusing on the Partner
money services business industry is highly identification of potentially suspicious Grant Thornton LLP
entrepreneurial, dynamic, diverse and transactions—perhaps this is simply
serves the needs of many Canadians and an evolution of the compliance regime
Canadian residents-to-be. exercise now that the rest of the program
elements are in place.
2

3. Contents
Introduction 4
Purpose 4
Methodology 5
Profile of the MSB population 6
Types of services offered by the MSBs 6
Geographical regions served by the MSBs 6
Types of clients served by the MSBs 7
Customer interaction types 7
Size of the MSB: number of locations, employees, use of agents 7
Documented contracts with agents 7
Agent monitoring: background due diligence and regular site visits 8
Review of AML compliance program 8
Compliance program elements 8
Policies and procedures 8
Compliance officer 9
The risk assessment 9
Training 10
Testing as part of training 10
Recordkeeping 11
Transaction processing system 11
Transaction reporting (large cash and electronic funds transfers) 12
Suspicious transactions 12
Terrorists and designated individuals 13
Public notice of administrative monetary penalties 14
About Grant Thornton LLP 15
3

4. Introduction
Every year around the world, large “self-banked” in communities across this report can help both MSB and
amounts of funds are generated from the country. These services are targeted financial institutions by establishing
illegal activities including drug trafficking, by and vulnerable to money laundering today’s benchmark and tomorrow’s
tax evasion, people smuggling, theft, arms and those wishing to finance terrorism. goals for AML compliance programs.
trafficking and corrupt practices. Money FINTRAC reports indicate that MSBs Specifically, to assist:
laundering—the process of concealing the are the second most used sector for • with identifying and evaluating the
source of illegally obtained money—plays money laundering and terrorist financing prevalence of compliance practices
a crucial role in allowing criminals to schemes after financial institutions, found within the MSB industry;
continue to perpetrate these crimes. and that transactions through MSBs • in determining the impact that specific
Money laundering and terrorist financing represent 36% of all case disclosures practices can have on a compliance
is a global phenomenon, with the made by FINTRAC to law enforcement.2 program’s effectiveness;
estimated amount of money laundered A rigorous and effective anti-money • MSBs with establishing effective
globally in any one year ranging from laundering and terrorist financing compliance practices and to determine
2–5% of global GDP, or US$800 billion deterrence program is a critical success the relative standing of their
to US$2 trillion.1 factor for today’s MSB organizations. organization within the industry;
In Canada, the Proceeds of Crime • MSBs in managing their relationships
(Money Laundering) and Terrorist Purpose with financial institution partners; and
Financing Act (PCMLTFA) created This benchmarking report was created • regulators in understanding the
the Financial Transaction and Reports with the goal of providing MSBs and industry’s compliance practices and to
Analysis Centre of Canada (FINTRAC), financial institution organizations—both evaluate the pace at which changes in
Canada’s financial intelligence unit. Over with AML compliance objectives—a the industry are progressing.
the past decade, regulated organizations critical tool to assist in evaluating the
across the country have worked to results of an AML compliance program
protect the integrity of Canada’s financial review and any planned program changes.
systems by implementing programs to It is our experience that the AML
comply with the PCMLTFA and its compliance programs of MSB
regulations and by reporting transactions organizations are just now starting to
to FINTRAC. deliver the rigour and effectiveness that
Two popular services offered by serve to protect Canada’s financial
money services businesses (MSBs), foreign systems from abuse by those with illegal
exchange and money remittance service funds or criminal intent. We believe that
providers, play a vital role in providing
financial services to the “unbanked” and 2 “Money Laundering and Terrorist Financing Trends in
FINTRAC Cases Disclosed Between 2007 and 2011,”
1 “Money-Laundering and Globalization,” United Nations Office FINTRAC Typologies and Trends Reports (April 2012):
on Drugs and Crime: http://www.unodc.org/unodc/en/ http://www.fintrac.gc.ca/publications/typologies/2012-04-
money-laundering/globalization.html eng.asp
4

5. Methodology was used to assist with determining the
The information used within this report prevalence of specific characteristics and
is the aggregation of knowledge that practices. In several areas throughout this
the AML team at Grant Thornton has benchmarking report we measured the
obtained by performing over 150 AML- number of MSBs out of the benchmarking
related engagements, including over 100 population that had deficiencies in specific
different MSB organizations for areas. Deficiencies are defined specifically
compliance with the PCMLTFA and as items or areas where the MSB’s
regulations. This report also incorporates documentation, process or reporting was
information obtained from publicly not sufficient to meet the requirements of
available sources. the PCMLTFA and its regulations.
The data used to compile this In evaluating the effectiveness of
benchmarking report has been reviewed the various MSB compliance program
to ensure that the confidentiality of each elements, different measures were used
individual entity is maintained, and that to measure different characteristics
the inclusion of information could not be depending on the available information.
used to identify an individual business or For example, the use of an automated
MSB organization. Only overall summary versus manual transaction processing
statistics for the population of data system was used to understand the
available to us or subset (as appropriate of occurrence, or effectiveness of identifying
the population) were used. transactions suspicious of money
In determining the prevalence of a laundering which were then subsequently
characteristic or practice in the industry reported to FINTRAC. Whereas, we
we only included information which we reviewed whether or not employee
assessed as being reasonable to rely on. testing as part of an MSB’s training
The same MSB may have been reviewed process was effective by comparing this
more than once and only the last instance practice against the level of record keeping
of review results was used. Furthermore, deficiencies identified.
information from AML reviews as well
as risk assessment assistance engagements
5

6. Profile of the MSB population
This section of the report provides SERVICES OFFERED BY THE MSBS INCLUDED IN THE BENCHMARKING POPULATION
PERCENTAGE OF MSBS OFFERING
background information to help the user
understand the profile of the MSBs
70%
included in the benchmarking population.
60%
Types of services offered by the MSBs 50%
The majority of MSBs included in the 40%
benchmark population provide money 30%
remittance services and close to half of the 20%
population provide currency exchange 10%
services. Other services provided include 0%
cheque cashing, money orders, and Remittance Foreign Remittance Cheque Money order Payday
payday loans. Many of the MSBs provide exchange as an agent cashing loans
multiple of these services. This population
TYPE OF SERVICE
is fairly reflective of the data reported by
FINTRAC3 in Money Laundering and
Terrorist Financing (ML/TF) Typologies quarter of all of the MSBs that provide Money remittance services-regions
and Trends for Canadian Money Services money remittance services) provide served by the MSBs
Businesses (MSBs) – July 2010 wherein remittance services broadly to regions Europe Africa 8%
around the world—either using 1%
MSBs were reported as predominantly
providing money remittance services established global networks or using their Non-specific
own proprietary networks. Half of the 26%
(75%) and foreign exchange services (70%).
The graph to the right shows MSBs in the benchmark population, who Asia
50%
the services offered by the MSB provided remittance services, served or
benchmarking population (note that delivered funds to and from Asian
Middle East 5%
many MSBs offer more than one of the countries. When we looked at the
listed services). remittance networks that were being used, South America 10%
we found that more than half of all MSBs
Geographical regions served by MSBs used only a proprietary network (57%), Remittance networks
who provide remittance services with the remainder being divided between
Of the MSBs that provide money those using only an established global
remittance services, we found that while a network (25%), or both (18%). Both
majority of the MSBs in the population 18%
typically serve a specific geographic Proprietary
region, a significant portion (just over a 57%
3 “Money Laundering and Terrorist Financing (ML/TF)
Established
Typologies and Trends for Canadian Money Services
Businesses (MSBs),” FINTRAC Typologies and Trends global network 25%
Reports (July 2010): http://www.fintrac.gc.ca/publications/
typologies/2010-07-eng.asp
6

7. Types of clients served by the MSBs Customer interaction Number of locations of the MSBs in the
Clients serviced by the MSBs include benchmarking population
Online only
corporate or other types of entities, 2%
individuals or a combination of both. More than 25
Corporate clients typically served include 6%
Six to 25
institutions or businesses who seek the 10%
services of the MSB to assist them with
making payments to foreign vendors. Multiple Face-to-face
Five or
access only
These transactions are usually for larger fewer 19%
50% 48%
dollar amounts. Individual clients are
One location
generally seeking the services of the MSB 65%
to perform smaller currency exchange
transactions, for the remittance of money Size of the MSB: number of locations,
to family members overseas or personal travel. employees, use of agents
The graph below shows the proportion While the MSB industry in Canada is
Documented contracts with agents
of MSBs that have corporate clients, dominated by a handful of larger businesses,
A documented contract between an MSB
individual clients, or both. While the there are also numerous smaller MSBs
and its agent(s) can clearly lay out the
majority of MSBs served both, some ranging in size from one location to larger
duties and obligations of each of the
MSBs have carved out a niche for organizations with hundreds of locations
parties and allow for an orderly means
themselves by serving a targeted in Canada and also abroad. Location has
of settling any disputes that may arise.
market, many of these involving a been defined for purposes of this
Over half (53%) of the MSB benchmark
specific ethnic community. benchmarking report to include branch
population did not have documented
and agent locations. Agents are individuals
contracts in place with their active agents,
Types of clients served by the MSBs or entities that are not directly employed
indicating that this is a business area
included in the benchmarking population by the MSB, but are authorized to act on
requiring attention.
behalf of the MSB to provide money
Individuals services to clients. Of the MSB benchmark
36% population, 24% provided services to Put in place documented contracts
clients using agents. A number of the which clearly lay out compliance
MSBs in the benchmark population had program obligations and provide
less than five employees, including owner right of audit to protect your
Both
62% operated, family-run businesses. organization. Up front background
Corporations due diligence and regular site visits
Number of employees of the MSBs in
2% to test compliance will protect your
the benchmarking population
organization over the longer term.
Customer interaction types More
The MSB benchmarking population was than 25
17%
analyzed to understand how the MSBs
interacted with their customers. The 11 to 25
percentage of MSBs providing online 8%
access to customers was only 2%, while
Five or fewer
48% interacted in person/face-to-face Six to 10 employees
access and 50% provided multiple forms 15% 60%
of access. For those organizations
providing multiple interaction types, these
were usually only provided after an initial
face-to-face meeting.
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8. Agent monitoring: background due
diligence and regular site visits
Less than half of the MSBs included in the
benchmarking population (only 38%) Compliance program
elements
conducted background due diligence
when first deciding to take on a new
agent. Further, only 37% of the MSBs
perform regular site visits of their agents.
Site visits usually included some testing,
inspection and inquiry of how regulatory
requirements were being adhered to. It
was not necessarily the same group of The most common policy and procedure
MSBs who performed both of these Make sure that your policies and deficiencies included:
procedures, only approximately half of procedures reflect and align with • insufficient detail of recordkeeping
the MSBs who conducted due diligence your money service business responsibilities (e.g., requirement to
also performed regular agent site visits. activities. Also ensure this is true for document beneficial ownership of
your risk assessment as well. If your corporate customers);
Review of AML compliance program risk assessment includes controls • no documentation of when and how
The MSB benchmarking population was to mitigate risk, these controls need to make third-party determinations;
analyzed to understand the percentage of to be performed. • no definitions of third-party and/or
MSBs whose compliance program had PEFP provided;
been subject to a prior review(s), whether • no documentation that the manual/
Policies and procedures
this was performed by Grant Thornton or policies and procedures had been
A required element of an MSB’s
another party. Approximately 28% of the reviewed and authorized by senior
compliance program is to have
benchmarking population had been management; and
documented compliance policies and
subject to more than one compliance • no documentation of the
procedures. The majority of the
program review. responsibilities of the compliance
benchmarking population (66% of the
For those MSBs who had more officer.
MSBs) had deficiencies identified in their
than one review of their program
program reviews. The remaining MSBs
completed, there was a marked decrease Policy and procedure deficiencies
with no identified deficiencies were likely
in documentation deficiencies (risk
to have more than five employees,
assessments and policy and procedures),
developed their policies and procedures
however, there still continued to be record
using external resources and a compliance
keeping and reporting deficiencies.
officer that had received external training. No deficiency
34%
Referrals are not enough. Deficiencies
Background due diligence results 66%
can be known within days. Focused
investigative research can identify
serious issues or concerns you
need to know about. Make sure you
get the facts about the people you
do business with—the potential
cost of failing to identify problems
can be prohibitively high.
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9. The risk assessment really needs to
be the foundation of your AML
program. Document your higher
risks and ensure you are actively
monitoring for these higher risk
customers and transactions. Once
identified, protect yourself and your
business by executing on your
documented controls such as
obtaining source of funds
information before you take on
responsibility for facilitating the
transaction.
Note: This bar chart provides detail data results for the pie chart on the previous page.
Only a small number of the MSBs had The risk assessment
The CO role requires expertise and compliance officers who were certified A good risk assessment documents
experience, and needs to be taken with relevant AML credentials (e.g. a specific money laundering and terrorist
seriously. In July 2012, HSBC’s certified anti-money laundering specialist financing risks specific to that individual
chief compliance officer resigned designation). We expect that going business and includes mitigating controls.
from the role amidst allegations forward more organizations will require This is a required element of the AML
that the bank had inadvertently this expertise and qualification of their compliance program regime for an MSB
allowed the laundering of Mexican compliance officers. and it can also be a roadmap to assist
drug cartel money. Of the MSBs in the benchmarking others with understanding the business,
population, 23% had a compliance the risks associated with the money
Compliance officer officer that was supported by a team service transactions facilitated, the
Each MSB is required to designate a providing assistance to oversee and meet customers and geographic regions
compliance officer (CO) responsible for the compliance program requirements. serviced. While most (94.5%) of the MSBs
its AML compliance program. The data We noted that for those MSBs with a in the benchmarking population had a
available in the benchmarking population compliance officer supported by a team, documented risk assessment, the majority
was analysed to try and understand who the rates of record keeping and reporting were still in the process of making the risk
was fulfilling the role and if and how this deficiencies were higher. This indicates assessment a practical reality of their
person was supported. In the benchmarking that while these teams are monitoring business operations. An effectively
population, 45% of the MSBs had the and processing a higher volume of implemented risk assessment
owner of the organization fulfilling the transactions, on-going management of fundamentally affects how an MSB
compliance officer role. In general, these the compliance program team is essential conducts their business.
MSBs were identified as smaller and more to ensure effectiveness of results.
likely to have policies and procedures
with identified deficiencies. For these
MSBs, it was also more likely that the
owner, for their compliance officer role,
received external training. There was no
marked difference regarding record
keeping or reporting deficiencies for
MSBs that had the owner as the
compliance officer versus MSBs which
had another individual fulfilling that role.
9

10. The benchmarking population Testing as part of training
indicates that most (84%) of the There are now MSB industry-tailored Testing reinforces learning. It also helps
MSBs did not have any high-risk areas training resources the MSB determine whether its training
identified in their risk assessment. Of available which organizations efforts have been effective, and provides
the MSBs that did identify high risks can access online and can also use additional motivation for staff. In the
(16%) these businesses were much more to track employee completion and benchmarking population, 24% of MSBs
likely to have had their documentation test results. use testing as part of their staff training
developed externally and to train their program, and 76% do not use any form of
compliance officer externally. However, documented testing. The MSBs that used
Testing doesn’t only reinforce
it is interesting to note that these same testing in their program were less likely to
learning, it helps the MSB understand have record keeping deficiencies and were
MSBs were less likely to file a suspicious
transaction report (STR). This is reviewed
the level of knowledge that its staff more likely to operate from one location.
in more detail later in this report. has. It also demonstrates a However, the testing of staff as part of an
commitment to AML and it locks MSB training program, did not have any
Training in your training investment. marked impact on whether or not an MSB
Documented ongoing training of the was reporting STRs. We expect this will
compliance program requirements must Training programs for staff may be change as training evolves to focus more
be maintained. We looked at how the developed internally or externally, or on how to identify suspicious transactions,
compliance officers of MSBs received and in combination. In the benchmarking with less focus on general awareness and
maintained their training and we looked at population, the majority (71%) of MSBs the recordkeeping requirements. We do
how the training for others in the used internal resources exclusively to believe the data reflects that testing
organization was delivered and train staff, 7% used external resources works—while MSBs with testing did have
maintained. In the MSB benchmarking exclusively and 22% used a combination recordkeeping deficiencies the rate of
population, the compliance officers were of programs. MSBs using internal deficiency were comparatively lower.
primarily obtaining their training by resources to train staff tended to have
accessing internal resources or visiting and lower rates of recordkeeping and Training should include materials
using the resources on the FINTRAC reporting deficiencies (albeit rates of
that are relevant to the employee’s
website. This group accounted for 65% of deficiency were still high). role within the organization, and
the compliance officers for which data should provide an understanding of
was available. The remaining 35% of Type of training
AML as well as specific knowledge
compliance officers were receiving
External necessary for that person to
external training. 7% perform their part of the MSB’s AML
There was no marked difference Both strategy. Don’t provide blanket
regarding recordkeeping or reporting 22%
training.
deficiencies between compliance officers
trained internally or externally. However,
the externally trained officers did have Train and review your specific
fewer identified deficiencies regarding recordkeeping requirements with
Internal
policy and procedure documentation 71% staff. Use examples specific to your
and risk assessments. It is essential to organization to make it effective.
remember that good training is only one
element of your compliance program,
and that all of the compliance program
elements need to be in place and working,
including the monitoring for and
reporting of suspicious transactions.
10

11. Testing in training
Use of testing
24%
No testing
76%
Note: This bar chart provides detail data results for the pie chart to the left.
Recordkeeping
In the benchmarking population, 76% of individuals authorized to transact for Transaction processing system
the MSBs had recordkeeping deficiencies. the corporation were not collected or Transaction processing system refers to the
Given the high rate of deficiency, we recorded; and manner in which a customer transaction is
looked in detail at the percentage of • for third-party and PEPF recorded. An automated transaction
records that had record keeping determinations no documentation that system refers to a system where the
deficiencies for each MSB, we then enquiries were made with client. customer’s information, as well as the
averaged and summarized this. Out of all transaction information is electronically
of the records reviewed, across all of the Occupation—this is really all about recorded and then processed. A manual
MSBs in the benchmarking population, an trying to understand the source of a system refers to a process for which both
average of 27% of the records tested person’s funds, how they earn their the customer and transaction information
contained deficiencies. We were able to money. Documenting that someone is first recorded manually (on paper).
identify two program elements which had is a manager doesn’t provide any Information from a manual system is kept
a positive impact on record keeping information as to source of funds. in paper format or it may be entered into a
(meaning that MSBs with these program Be specific and detailed. spreadsheet. In the benchmarking
elements had a lower rate of record population, 54% of MSBs used automated
keeping deficiency). These elements were transaction systems while 46% of MSBs
Don’t make assumptions for your used a manual system. The MSBs that used
the use of an automated system to process
transactions and the use of testing as part clients. When required, third party automated transaction systems usually had
of staff training. and politically exposed foreign more locations and processed a higher
The more typical recordkeeping persons enquiries need to be made volume of customer transactions.
deficiencies were: and documented. Also, for larger Automated systems also resulted in a higher
• staff was unclear as to what the transactions, ones out of pattern or likelihood of the MSB filing an STR report
specific recordkeeping requirements not expected for a client, enquire with FINTRAC. The rates of recordkeeping
were (i.e., were not obtaining address, and document as to source of deficiencies were high regardless of
telephone, date of birth information funds, don’t assume it. whether the MSB was using an automated
from clients); or manual transaction processing system.
• occupation information was either not
obtained or what was documented
was unclear (e.g., self-employed,
manager, owner);
• corporate beneficial ownership
information was not obtained or
documented, also details of the

12. The most common deficiencies were: Suspicious transactions
Even smaller MSBs that record
• late filings (most common); Most MSBs (73%) did not file any STRs
their transactions manually can with FINTRAC over the time period
• reportable transaction not identified
benefit from the low-cost solution reviewed which was generally a three
by the MSB until the completion of
of recording transactions on a month to one year timeframe. The data
the review (this was most common for
spreadsheet. This will help to indicates that it was typically larger MSBs
transactions meeting the 24-hour rule
identify anything suspicious and that filed STRs and that these
threshold); and
also demonstrate to others that organizations were more likely to use an
• filing incorrect information.
you have the ability to adequately automated transaction system, meaning
monitor your transactions. the organization likely had automated
monitoring procedures. As well, MSBs
that filed STRs were more likely to have
Ensuring that the 24-hour reporting
MSBs that filed STRs delivered their training using internal
rule requirement is met can be
resources and to have developed their
tricky for MSBs that process a high
policies and procedures internally.
volume of transactions using a
manual system. It will be harder
and harder to justify maintaining Filed STRs
manual records. Before you make 27%
the system investment, even the Have not
filed STRs
use of a simple spreadsheet can 73%
assist with ensuring the
requirements are met.
Transaction processing system
Manual
46%
Automated
54%
Transaction reporting (large cash and
electronic funds transfers)
In the benchmarking population, 66%
had large cash and/or electronic funds
transfers reporting deficiencies. Given the
high rate of deficiency, we looked in detail
at the percentage of transaction reports
that had reporting deficiencies for each
MSB, we then averaged and summarized
this. Out of all of the reports reviewed,
33.4% of LCT reports and 38.5% of EFT
reports had deficiencies.
Note: This bar chart provides detail data results for the pie chart above.
12

13. We identified that most of the MSBs in Terrorists and designated individuals Terrorist and designated individuals
the benchmarking population had We analyzed the data available to identify detection system
transactions which the MSB needed to how many MSBs were using an
review in order to determine whether or automated system to check customer
not any STR filing was required. At the names against available listings of
time of the review these MSBs had not sanctioned individuals and entities.
documented any form of previous Results showed that 57% of MSBs were Manual Automated
manually checking customer names, and 57% 43%
monitoring of these transactions. The
most commonly identified types of 43% had an automated process to do this
transactions were: for them. Most MSB organizations which
• numerous transactions made by the were manually checking were doing so
same customer over shorter time against the OSFI list only, whereas when
periods (e.g., one to ten days); and an automated process was used to do the
• larger transactions conducted by checking, usually multiple lists were Automated detection system
customers and source of funds checked, including at least the OSFI and with deficiencies
information was unknown or what OFAC lists.
was known/documented was not We determined that for the MSBs
clear/did not make sense. using an automated system, during
the time of their compliance program
review, 45% of these MSBs had identified No deficiency Deficiency
It’s critical that all staff (front deficiencies. 55% identified
45%
counter, back office/ processing, Deficiencies were specifically related to:
and management) are properly • the list the system was using to check
trained and aware of how to names against was not the most
recognize the red flags of an updated, and in some cases was several
unusual transaction—one suspicious months outdated; and
of money laundering or terrorist • technical issues with the system such Understanding source of funds: A
financing. Training is now expected that the comparison process was simply bank account is where the money
to be tailored to the role and not working as it was supposed to. last comes from before it comes to
position of your staff. your organization; knowing this is
not enough. Find out how the money
MSBs which are not identifying and came to be owned and in the control
reporting suspicious transactions to of your potential customer.
FINTRAC need to really stand back
and assess their risk, identification Transactions need to be monitored
and monitoring processes. Is their for unusual, potentially suspicious
compliance program really activity. Make sure this process is
effective? Today the expectation is documented.
that within this industry an effective
program will identify suspicious
transactions. If you are not
reporting, you need to be able to
prove that you don’t have to.
13

14. Public notice of administrative
monetary penalties
Posted on FINTRAC’s website are
persons and entities that have been issued
a monetary penalty where a “serious or
very serious” violation was committed
(15 MSBs in total).4 The chart to the right
summarizes the types of penalties cited
and provides comparison information on
the rate of occurrence across the MSBs
who were issued penalties. We note the
higher number of penalties regarding
compliance program documentation
versus the number of penalties regarding
the substantive results of a compliance
program, for example, the identification
and reporting of STRs.
4 As of September 1, 2012
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15. About Grant Thornton LLP
Grant Thornton is one of the world’s Our national anti-money We have made efforts to ensure
leading organizations of independent laundering team: information in this article is accurate as of
assurance, tax and advisory firms. These Jennifer Fiddian-Green, Patrick Ho, its original publication date, being
firms help dynamic organizations unlock Michelle Sarmiento, Dave Chu (Toronto); September 2012, however, we make no
their potential for growth by providing Pat McParland, Albina Alimerko representations as to its current accuracy.
meaningful, actionable advice through a (Vancouver); Al Bleau (Calgary) In addition, information or views
broad range of services. Proactive teams, Corey-Anne Bloom (Montreal) expressed herein are provided on an
led by approachable partners in these informational basis only and should not
firms, use insights, experience and instinct Toll-free line and email to directly be taken as official statements of position,
to solve complex issues for privately contact our national AML team: or be considered technical advice. For
owned, publicly listed and public sector T +1 855 747 2647 more information about the topics
clients. Over 31,000 Grant Thornton E msb@ca.gt.com expressed herein, please contact a Grant
people, across 100 countries, are focused Thornton adviser in your area who will be
on making a difference to clients, happy to answer your questions.
colleagues and the communities in which
we live and work.
About Grant Thornton in Canada
Grant Thornton LLP is a leading
Canadian accounting and advisory firm
providing audit, tax and advisory services
to private and public organizations.
Together with the Quebec firm Raymond
Chabot Grant Thornton LLP, Grant
Thornton in Canada has approximately
4,000 people in offices across Canada.
Grant Thornton LLP is a Canadian
member of Grant Thornton International
Ltd, whose member firms operate in close
to 100 countries worldwide.
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